We are going to modify mortgage loans and add the escrows (taxes and insurance) to the principal of the loan. We will not replace the existing note. Since we are not replacing the existing note, TRID disclosures are not required correct even we are increasing the principal amount of the loan? Customer is unable to pay for the new escrow payment after the deferment of payments was done last year. A new escrow analysis will be done.

Thank You

That is sort of a grey area. If you are funding an initial deposit into an escrow account, those amounts would not be due or accrued under the current obligation.

Paragraph 20(a)(4)

1. Workout agreements. A workout agreement is not a refinancing unless the annual percentage rate is increased or additional credit is advanced beyond amounts already accrued plus insurance premiums.

Thank you. It's not the initial deposit. it's the escrow shortage caused by the deferment of payments.

You can roll in actual amounts that the bank has actually paid on behalf of the consumer out of bank funds such as property taxes or advance money for the purchase of an actual insurance policy. If you are funding an escrow shortage or an initial escrow deposit - that is really not the same thing. You probably need to be having a discussion with your legal counsel.